Westlaw Headnote of the Day – December 23, 2010

December 23, 2010

West's Key 220 Internal Revenue
West's Key 220V Income Taxes
West's Key 220V(A) In General
West's Key 220k3071 k. Substance or Form of Transaction.

Taxpayer may engineer his transactions to minimize taxes but cannot make a transaction appear to be what it is not; documents record transactions but do not always become sole criteria for transactional analysis for tax purposes.
Redwing Carriers, Inc. v. Tomlinson, 399 F.2d 652 (5th Cir. 1968)